WorkflowRegulatory Affairs

EU MDR Technical Documentation Review

EU MDR technical documentation review that finds the gap and the contradiction before the notified body does

Technical files that pass notified body review the first time, every requirement cited.

See one case, screen by screen ↓
demo9,412pagesin 186 documents of one class III technical file, read and sorted into Annex II by the agents
demo3contradictionsfound between documents on the sample file — shelf life, rated burst pressure and UDI-DI, each with both pages
target0roundsof notified body questions expected, down from 3 on the last file
target5daysper technical file review, down from 6 weeks
In short

What is EU MDR Technical Documentation Review?

It is the check, before submission to a notified body, that the Annex II technical documentation proves the device meets every applicable General Safety and Performance Requirement in Annex I of Regulation (EU) 2017/745. EU MDR Technical Documentation Review does it with five agents that map each GSPR line to the document, revision and page that meets it, check standard editions and cross-read facts between documents, for a regulatory lead to decide and sign.

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Updated

The problem

Why a technical file still comes back with questions

A class III technical file is close to two hundred documents and thousands of pages: the device description and specification, label artwork and IFU, design and manufacturing information, the GSPR checklist, the risk management file, bench, biocompatibility, sterilisation and aging reports, and the clinical evaluation. Before submission a regulatory affairs lead walks the GSPR checklist line by line in a spreadsheet, looking for the document and page that meets each Annex I requirement — about six weeks per file for one reviewer.

What the notified body finds is what nobody had time to cross-read. A shelf life extended by change control in the design file but never on the label. An IFU chart copied from a sister device's template. A UDI-DI with two digits swapped in the draft Declaration of Conformity. A biological evaluation still on a superseded edition of EN ISO 10993-1. A line marked “not applicable” with no reason. Each one can mean another round of questions, and legacy devices must hold an MDR certificate by 31 Dec 2027 or 2028 while notified bodies most often take 13–18 months to certify.

typical13–18monthsmost often, for a notified body to issue an MDR certificate
demo61questionsover 3 rounds on the sister device's last file
demo6weeksto review one file by hand, one reviewer
Where a technical file review's working days goestimated
By hand30 days
With the solution5 days
  • Indexing the file and finding the released revisions4 → 0.5 d
  • Mapping each GSPR line to a document and page12 → 1.5 d
  • Checking the edition of every standard cited3 → 0.3 d
  • Cross-reading the same facts between documents6 → 1 d
  • Writing “not applicable” reasons and the gap list3 → 0.8 d
  • Drafting, second review and signing the report2 → 1 d

Estimated split for one class III technical file reviewed before submission, by hand and with the solution.

How it works

How a technical file is reviewed

Five specialist agents index, map, check and cross-read every technical file; a regulatory lead decides and signs.

What comes in
Technical file in186 documents · Annex II, released revisions
Agents at work
File indexerAnnex II sections
Then
GSPR mapperdocument and page
Standards checkercurrent editions
Then
Consistency checkerfacts side by side
Then
Review report writercited draft
A person decides
Regulatory leaddecides and signs
What comes out
GSPR checklist with evidence
Contradictions fixed first
Signed review
One case, step by step

One technical file, from released documents to a signed review

Corvane Medical must move Calvera NC, a class III coronary dilatation catheter with a non-compliant balloon, from its legacy MDD certificate to an MDR certificate by 31 Dec 2027. Submission to the notified body is planned for 30 Nov 2026. Here is the pre-submission review, screen by screen, in the working solution.

  1. 01Morning

    The whole of Annex I on one board

    Ingrid Halvorsen · Regulatory affairs lead, devices

    Ingrid opens the GSPR board for Calvera NC: one ring per Annex I section, grouped by chapter. The file stands at 86% — 88 of 102 applicable lines evidenced, 11 gaps, 3 contradictions, and 79 lines not applicable, each with a reason. Section 23, label and instructions for use, sits at 80%, 32 of 40 lines, with two red notches.

    “Labels and IFU drew 22 of the 61 questions the notified body asked about Calvera SC in 2025 — including shelf life (Q14) and the symbols standard (Q9).”

  2. 02One click

    “Review the file” — five agents read 186 documents

    The agents

    The file came from the document control system on 9 Oct 2026: 186 documents, 9,412 pages. The file indexer sorts them into the six sections of Annex II and sets 14 superseded revisions aside, never cited. The GSPR mapper sorts 181 checklist lines into 102 applicable and 79 not applicable, then finds evidence for 88. The standards checker compares 24 standards, the consistency checker reads 8 facts in 46 places, and the review report writer drafts the report.

    4 h 12 min of agent time — every step shown with what it found.

  3. 03Line 10 · B1

    A gap the notified body has asked about before

    GSPR mapper

    The biological evaluation report BER-019 follows ISO 10993-1:2009; the current edition is EN ISO 10993-1:2020. The line becomes gap G-03, with a suggested fix — update the biological evaluation plan and report to the 2020 edition, or justify — owned by Mateo Lindgren, due 6 Nov. The same issue was round 1, Q31 on Calvera SC.

    The GSPR mapper never marks a line evidenced without a page citation.

  4. 04Consistency

    The same eight facts, read from every document

    Consistency checker

    Device classification, sterilisation method, shelf life, UDI-DI, Basic UDI-DI, intended purpose, storage conditions and rated burst pressure are read from 46 places in 14 documents, each value with its page. Five facts are the same everywhere. Three disagree, and each red cell opens both pages.

  5. 05Contradiction C-01

    Shelf life: 36 months or 24 months?

    Ingrid Halvorsen · Regulatory affairs lead, devices

    Side by side: the device description and specification DS-114 rev C, p. 12, reads 36 months from date of manufacture; the label artwork LA-0388 rev B, panel 2, sets use-by at date of manufacture + 24 months. Change record CR-0412, approved by Annika Brandt on 18 Mar 2025, extended shelf life to 36 months on the accelerated aging report TR-2291 rev C (ASTM F1980, 55 °C). It listed DS-114, MP-220 and the GSPR checklist as affected — not the label artwork or the IFU.

    “The agents never choose the value. The fix goes through change control; the ring stays red until the corrected document is released.”

  6. 06Decided

    She aligns the label and IFU, before the notified body asks

    Ingrid Halvorsen · Regulatory affairs lead, devices

    Three options: align the label artwork and IFU to 36 months, keep 24 months and correct the design file until real-time aging confirms 36 (Mar 2028), or mark it not a contradiction with a written reason. The evidence supports the first. Ingrid decides and assigns: change CR-0431 for LA-0388 and IFU-0388 §11, owner Tomás Reyes, due 24 Oct, approval Annika Brandt.

    The notified body asked before — round 1, Q14: “Provide the evidence supporting the shelf life stated on the label and confirm it is consistent with the device description.”

  7. 07Contradiction C-02

    Rated burst pressure: 18 atm or 20 atm?

    Consistency checker

    DS-114 p. 9 and the bench report TR-2207 give 18 atm, demonstrated at 99.9% reliability and 95% confidence. The IFU v4 compliance chart on p. 7 says 20 atm, because it was rebuilt in 2024 from the Calvera SC template. The third, C-03, is a UDI-DI with its last two digits swapped in the draft Declaration of Conformity — a number that fails the GS1 check digit.

    Supported by the evidence: correct the IFU compliance chart to 18 atm — change CR-0432, Tomás Reyes, due 24 Oct.

  8. 08Gaps

    Every gap with an owner and a date before submission

    Ingrid Halvorsen · Regulatory affairs lead, devices

    Eleven gaps, each with the line it breaks, what is missing, the fix, an owner or a suggested owner, and a due date: residual risks R-12 and R-13 missing from the IFU, a summative usability evaluation run on IFU v3, EO residuals not tested on the 2025 load, no “MD” symbol on the label. Four were asked about by the notified body before. The decided shelf-life change now sits at the top as CR-0431.

    G-05: magnetic resonance safety marked “not applicable” with no reason — suggested owner Mateo Lindgren, due 17 Oct.

  9. 09The report

    The pre-submission review, drafted from the results

    Review report writer

    RA-REV-0388 version 0.3: the scope, results by chapter, the three facts that disagree with the decision on each, or open, the 11 gaps, the 3 standards out of date, and where questions are likely — Q9 symbols, Q14 shelf life, Q22 residual risks, Q31 biological evaluation, Q40 usability. It recommends correcting the three contradictions and closing gaps G-01, G-03 and G-06 before submission.

    “With owners and dates as above, submission on 30 Nov 2026 remains achievable.”

  10. 10Signed

    Second review done; the regulatory lead signs

    Annika Brandt and Ingrid Halvorsen

    Annika Brandt, quality manager, completed the second review at 10:20, as she does for every class III file. Ingrid signs with her name, password and the meaning “Review complete — gaps assigned before submission”. Contradictions still open stay on the report as open items, and version 1.0 is kept with the technical file.

    The review report writer never signs or submits anything.

Who it’s for

Built for everyone who owns a technical file.

The same file, seen by the four people who carry it to the notified body — what their review looked like, and what it looks like now.

IH
Ingrid HalvorsenRegulatory affairs lead · signs every pre-submission review
Regulatory affairs lead, devices
Before
Owns 14 legacy device files due at the notified body and walks each GSPR checklist by hand for six weeks — and the notified body still comes back with rounds of questions.
Now
Opens a board that shows every Annex I section, every gap and every fact that disagrees, decides each contradiction and signs. “I would rather find the contradiction than have the notified body find it.”
TR
Tomás ReyesTechnical file author · owns labels and IFU content
Technical file author
Before
Assembles and updates the Annex II file, and learns about a label that never caught up with a change when the questions arrive.
Now
Gets each gap and change with the line it breaks, the page that is wrong and what it should say — CR-0431 for the label and IFU, due 24 Oct.
ML
Mateo LindgrenR&D design engineer · coronary catheters
R&D design engineer
Before
Owns design verification, the bench tests and the aging study. “The data supports 36 months — the label just never caught up.”
Now
Sees his reports cited page by page, and the gaps that are his — the biological evaluation edition, the bridging usability evaluation — with the question the notified body asked last time.
AB
Annika BrandtQuality manager · second reviewer for class III, change control
Quality manager
Before
Runs change control and document control, and is the second reviewer on every class III file.
Now
Approves the changes the decisions raise and completes the second review on the drafted report before the regulatory lead signs. “Every fix goes through a change record, with a version.”
Built on the engine

5 agents. Each with one job, and hard limits.

Five specialist agents index, map, check and cross-read every technical file; a regulatory lead decides and signs.

File indexer

Reads every document in the technical file and sorts it into the six sections of Annex II, with document number, title, revision, pages and release status. Superseded revisions and drafts are read but set aside.

  • Never edits or replaces a controlled document
  • Only released revisions count as evidence
GSPR mapper

Decides for each line of the GSPR checklist whether it applies to the device, finds the passage that meets it and cites document, revision and page, names the standard applied, opens a gap where there is none and drafts a reason for every line that does not apply.

  • No page citation, no evidence
  • “Not applicable” always needs a reason, and a person accepts every reason
Standards checker

Lists every standard the file cites and compares the edition cited with the current and harmonised edition — 24 standards on the sample file, 3 out of date.

  • Never decides a standard is not needed — that is the regulatory lead's call
Consistency checker

Reads the same fact from every document that states it, compares the values and shows any disagreement side by side with every other statement and the change record or template history that explains it.

  • Never chooses which value is right
  • Every value cites its page
Review report writer

Drafts the pre-submission review report from the results: chapter totals, contradictions and their decisions, gaps with owners, standards out of date and where questions are likely.

  • Never signs or submits
  • Open items stay on the report
Regulatory lead

Decides every contradiction and signs. The agents propose; a named person decides.

Ask in plain words

Ask about any requirement, document or contradiction

Ask in plain words, or say what to change. Every answer points to the page it came from.

Where will the notified body ask first?

In section 23, labels and IFU — it sits at 80% and drew 22 of the 61 questions on Calvera SC. Two facts disagree there: shelf life is 36 months in the design file and 24 months on the label artwork — exactly what Q14 asked about last time — and the UDI-DI is mistyped in the draft declaration. Next: residual risks (section 4, Q22) and the biological evaluation edition (section 10, Q31).

Why does the shelf life disagree?

Change record CR-0412 extended shelf life to 36 months in March 2025 on the accelerated aging report TR-2291 rev C. The label artwork was released in January 2025 with date of manufacture + 24 months, and CR-0412 did not list it as affected — nor the IFU. The evidence supports aligning the label and IFU to 36 months; real-time aging will confirm it by March 2028.

Which standards are out of date?

Three of 24. The biological evaluation report cites ISO 10993-1:2009; the current edition is 2020 (gap G-03, asked as Q31 last time). The EO residuals report cites EN ISO 10993-7:2008 without its 2022 amendment. The label and IFU use symbols from EN ISO 15223-1:2016; the current edition is 2021 (gap G-06, Q9).

Assign the gaps no one owns

Done. G-05 (MR safety marked not applicable with no reason) goes to Mateo Lindgren, due 17 Oct, and G-10 (three IFU translations) to Tomás Reyes, due 13 Nov. Both owners get a task; every gap now has an owner before the 30 Nov submission.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The GSPR boardOne ring per Annex I section: evidence fills it, empty arcs are gaps, red notches are contradictions, dashed rings are not applicable, and a dot marks what the notified body asked before.
The file and the agents at work186 documents, 9,412 pages sorted into Annex II, and each agent's step with what it found and how long it took.
One requirementThe Annex I text, the gap and its suggested fix, the standard applied, the owner, and what the notified body asked before.
Consistency across the fileEight facts read from 46 places in 14 documents, each value with its page; the three that disagree in red.
Two pages side by sideShelf life at 36 months in DS-114 p. 12 and 24 months on label artwork LA-0388 panel 2, why they differ, and the three choices.
Decided and assignedThe decision, the change it raises with an owner and date, the notified body's earlier question, and every document that states the fact.
Rated burst pressure18 atm in the specification and bench report, 20 atm in the IFU compliance chart copied from a sister device's template.
GapsEvery requirement without evidence, with the section, what is missing, the fix, an owner, a due date and whether it was asked before.
Standards24 standards cited, the edition cited against the current edition, where each is cited and the 3 out of date.
Legacy devices moving to MDR14 devices on directive certificates, €62M a year of EU sales, each deadline and planned submission, and when every file is reviewed — with agents and by hand.
The pre-submission review reportScope, results by chapter, facts that disagree, gaps, standards, where questions are likely and the recommendation, with the sign-off.
Sign the reviewThe signer, the meaning of the signature and a warning that open contradictions stay on the report as open items.
Your rulesThe GSPR checklist template, evidence and “not applicable” rules, released revisions only, and the facts to cross-check.
Governance

Built for notified body review: cited, decided, signed.

No page, no evidenceEvery evidenced line cites document, revision and page. A line without a page reference stays a gap, and only released revisions are cited — drafts and superseded revisions are read, never used as evidence.
Every “not applicable” has a reasonThe GSPR mapper drafts a reason for each line that does not apply; the regulatory lead accepts it or marks the line applicable. A line marked not applicable with no reason becomes a gap.
A person decides every contradictionThe consistency checker shows both pages and the change record that explains them. Choosing which value is right is always the regulatory lead's decision, and marking “not a contradiction” needs a written reason that stays on the report.
Controlled documents stay controlledThe agents never edit a controlled document; released documents are read from the document control system and nothing is written back. Every fix goes through change control with a version, and the ring stays red until the corrected document is released.
Second review, then a signature with meaningFor class III files the quality manager completes a second review. The regulatory lead signs the report electronically with name, time and meaning, and the signed version is kept with the technical file.
Every step on the recordEach agent step, decision, assignment and signature is recorded with who, what and when, and each version of the review report is kept.
Configuration

Your review rules, not ours

How a technical file is reviewed is set once, in settings — the checklist, the evidence rules, the facts to cross-check and who signs.

SettingDefaultChoose from
GSPR checklistCorvane template v5 · 181 linesAnnex I broken into the lines your reviewers answer
Evidence must cite document, revision and pageOnOn · off — a line without a page reference stays a gap
“Not applicable” needs a reasonOnOn · off — drafted by the agents, accepted by the regulatory lead
Use only released revisionsOnOn · off — drafts and superseded revisions are read, never cited
Facts to cross-check8 factsEach fact on or off · add a fact
Standards editionsRefreshed monthlyCurrent editions and the harmonised standards list
Notified body question historyCalvera SC, 2025 · 3 rounds · 61 questionsImported — used to mark where questions are likely
Sign-offRegulatory lead signs · quality manager second review for class IIIElectronic signature with name, time and meaning
Connections

Works with the technical file you already keep

Technical file (Annex II)device description, labels and IFU, design and manufacture, risk management, verification and clinical data
GSPR checklistyour company template of Annex I, line by line
Standardsthe editions cited, current editions and the harmonised standards list
Change recordsto explain why two documents disagree
Notified body question historypast rounds of questions, to mark where they are likely
Document control systemreleased documents read only — nothing is written back
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
0rounds
of notified body questions expected, down from 3 on the last file
Last file3 rounds · 61 questions
With agents0 rounds expected
target
14of 14
legacy devices reviewed before the 2027 deadline, keeping €62M a year of EU sales on the market
files reviewed in time
target
5days
per technical file review, down from 6 weeks
By hand6 weeks
With agents5 days

“demo” = seen in the working solution, on its sample technical file · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (European Commission notified body survey, 2025 — most often 13–18 months to an MDR certificate). Regulation (EU) 2017/745 Annex I and II; Regulation (EU) 2023/607 for the 31 Dec 2027 and 2028 transition deadlines. People, companies, devices and sales figures named on this page are fictional — characters and sample data in the working solution.

Questions

What device regulatory teams ask us.

What is EU MDR technical documentation review?

It is the check, before submission to a notified body, that the Annex II technical documentation proves the device meets every applicable General Safety and Performance Requirement in Annex I of Regulation (EU) 2017/745. EU MDR Technical Documentation Review does it with five agents that map each GSPR line to the document, revision and page that meets it, check standard editions and cross-read facts between documents, for a regulatory lead to decide and sign.

How does it fill in the GSPR checklist?

The GSPR mapper works through your own checklist template line by line. For each line it decides whether it applies, cites the passage that meets it with document, revision and page and the standard applied, opens a gap where there is no evidence and drafts a reason for every line that does not apply — which the regulatory lead accepts.

How does it find contradictions between documents?

The consistency checker reads a list of facts — classification, sterilisation method, shelf life, UDI-DI, Basic UDI-DI, intended purpose, storage conditions, rated burst pressure — from every document that states them. Values that disagree open as two pages side by side, with every other statement and the change record that explains the difference. You can add your own facts to the list.

Does it check that the standards cited are current?

Yes. The standards checker lists every standard the file cites and compares the edition cited with the current edition and the harmonised standards list, refreshed monthly. A superseded edition, or an amendment not applied, needs an update to the document or a written justification.

Does the AI decide which value is right, or change our documents?

No. The agents never choose the value in a contradiction and never edit a controlled document; released documents are read from your document control system and nothing is written back. The regulatory lead decides, and every fix goes through change control with a version.

Do people stay in control of the review?

Yes. The regulatory lead decides every contradiction, accepts or rejects each “not applicable” reason and signs the review report with name, time and meaning. For class III files the quality manager completes a second review first, and the report writer never signs or submits anything.

Does it cover post-market records?

No. Its scope is the technical documentation under Annex II — device description, information supplied, design and manufacture, the GSPR, benefit-risk and risk management, and verification and validation.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your GSPR checklist template, review rules, standards list and a released technical file — and it goes live once every quality gate has passed. We will walk you through it on one of your own legacy device files first.

See it on
your technical files.

We'll run EU MDR Technical Documentation Review on one of your own legacy device files.